G.R. No. L-43648 July 26, 1976
WENCESLAO CENTENO, petitioner, vs. WORKMEN’S COMPENSATION COMMISSION and BATANGAS LAGUNA TAYABAS BUS COMPANY, respondents.

FACTS

Petitioner Wenceslao Centeno was awarded disability compensation for his work-related Pulmonary Tuberculosis by the Workmen’s Compensation Commission in a final and executory decision dated September 17, 1975. The decision ordered the respondent Batangas Laguna Tayabas Bus Company to pay him P6,000.00 under Section 14 of the Workmen’s Compensation Act and to provide necessary medical services, appliances, and supplies under Section 13 of the same Act. On November 26, 1975, Centeno received and acknowledged payment of the P6,000.00 disability compensation by signing a document labeled “Full Satisfaction of Decision.”
Subsequently, on December 10, 1975, Centeno, who was still undergoing treatment and confined at a medical center, filed a Motion for Execution to compel the bus company to reimburse his ongoing medical and hospitalization expenses, which amounted to P2,047.53. The Acting Referee granted this motion. However, the respondent Commission, on appeal by the bus company, reversed the referee. The Commission ruled that its September 1975 decision had become final, that the regional office lost jurisdiction, and that Centeno’s “Full Satisfaction” document constituted an amicable settlement barring further claims.

ISSUE

Whether the petitioner’s execution of a “Full Satisfaction of the Decision” receipt for the disability compensation award precludes him from claiming reimbursement for subsequent medical and hospitalization expenses as also decreed in the final decision.

RULING

The Supreme Court ruled in favor of the petitioner, setting aside the Commission’s order. The legal logic is anchored on the non-waivability of statutory benefits and a strict construction in favor of labor. The document signed by Centeno was merely a receipt for the specific P6,000.00 disability benefit under Section 14 of the Act. It could not be construed as a waiver of his separate and distinct right to continuing medical services and reimbursement under Section 13, which was also part of the final award. The law expressly nullifies any contract or device intended to exempt an employer from liability under the Workmen’s Compensation Act.
Furthermore, the employer’s liability for medical services persists for the duration of the disability stemming from the compensable illness, irrespective of the termination of employment or the finality of a compensation award. The duty to provide medical aid is continuous. The Court emphasized that labor laws must be interpreted liberally in favor of the worker, especially when dealing with a necessitous employee seeking recovery. Since the need for medical treatment continued after the award’s finality, the Motion for Execution was the proper remedy to enforce that unfulfilled portion of the judgment. Therefore, the referee’s order for reimbursement was reinstated.